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    <title>1997 (10) TMI 44 - ALLAHABAD High Court</title>
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    <description>Rectification under section 154 of the Income-tax Act, 1961 cannot be used to withdraw interest allowed under section 214 where the legal position is debatable and two reasonable views are possible. The Court held that the question whether further interest was payable up to the date of rectification was not a patent mistake apparent from the record, since there was support for the assessee&#039;s position and the issue involved mixed factual and legal arguments. The rectification order was therefore beyond the scope of section 154, and the Tribunal&#039;s cancellation of that order was upheld in favour of the assessee.</description>
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    <pubDate>Tue, 14 Oct 1997 00:00:00 +0530</pubDate>
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      <title>1997 (10) TMI 44 - ALLAHABAD High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=16563</link>
      <description>Rectification under section 154 of the Income-tax Act, 1961 cannot be used to withdraw interest allowed under section 214 where the legal position is debatable and two reasonable views are possible. The Court held that the question whether further interest was payable up to the date of rectification was not a patent mistake apparent from the record, since there was support for the assessee&#039;s position and the issue involved mixed factual and legal arguments. The rectification order was therefore beyond the scope of section 154, and the Tribunal&#039;s cancellation of that order was upheld in favour of the assessee.</description>
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      <pubDate>Tue, 14 Oct 1997 00:00:00 +0530</pubDate>
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